Appendix B 

Staff Summary of and 

Brief Response to 

Comments on the Final Program EIR/EIS 

Prepared by: 

California High-Speed Rail Authority 

925 L Street, Suite 1425 

Sacramento, CA 95814 

Contact: Mr. Dan Leavitt 

916/324-1541 

November 2, 2005 
California High-Speed Rail Authority. 2005. Staff summary of and brief 

response to comments on the final program EIR/EIS. November 2. 

Sacramento, CA. 

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Appendix B 

Table of Contents 

1.1 Introduction .................................................................................1 

1.2 Summary of Comments Received on the Final 

EIR/EIS .......................................................................................1 

1.2.1 Hal B.H. Cooper ..............................................................1 

1.2.2 Joseph P. Thompson ......................................................2 

1.2.3 John F. (Jack) Munro ......................................................3 

1.2.4 Dianne Domingo-Foraste M.D.; and 

Mayisha Akbar (founder of the Jr. Posse 

Youth Equestrian Culture Center ....................................4 

1.2.5 Joyce Dilliard...................................................................5 

1.2.6 Stuart Flashman on behalf of Train Riders 

Association of California, the Planning and 

Conservation League, and Defense of 

Place ...............................................................................5 

1.2.7 Sierra Club (signed by Patrick Moore, 

Chair, Transportation Committee, Loma 

Prieta Chapter)................................................................8 

1.2.8 U.S. Environmental Protection Agency .........................11 

1.2.9 Libby Lucas ...................................................................14 

1.2.10 State Parks....................................................................15 

1.2.11 State Parks Foundation.................................................17 

1.2.12 City of Visalia ................................................................19 

1.2.13 City of Palmdale ............................................................19 

1.2.14 Natural Resources Defense Council .............................19 

1.3 Erratum .....................................................................................18 

CALIFORNIA HIGH SPEED RAIL AUTHORITY

i
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

ii

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS

1.1 Introduction 

This attachment to the Staff Report for the Final Program Environmental Impact 

Report/Environmental Impact Statement (EIR/EIS) for the Proposed California 

High-Speed Train System summarizes comments received on the Final Program 

EIR/EIS for the proposed California High-Speed Train System. 

No comments were received that provided significant new information (as defined 

in the State California Environmental Quality Act Guidelines section 15088.5(a) or 

40 Code of Federal Regulations 15029(c)(1)); therefore, recirculation is not 

required. 

1.2 Summary of Comments Received on the 

Final EIR/EIS 

1.2.1 Hal B.H. Cooper 

Hal B. H. Cooper submitted a letter and an attached report on September 16, 

2005, and a background report on November 1, 2005, in response to the 

publication of the notice of the Final Program EIR/EIS. As discussed below, the 

letter and reports are in addition to Mr. Cooper’s comments on the Draft Program 

EIR/EIS (Comment Letter PH-F031 on April 28, 2004 & O008 dated June 02,

2004). 

Mr. Cooper’s letter of September 16 enclosed for the Authority’s review a proposal 

Mr. Cooper had submitted to the District 7 Office in Los Angeles of the California 

Department of Transportation. This proposal (private sector financing of a new 32 

mile long electrified railroad tunnel through the Tehachapi Mountains under the 

Grapevine Grade between Grapevine and Castaic) was discussed in Mr. Cooper’s 

previous submittals on the Draft Program EIR/EIS. This 32-mile-long tunnel is part 

of a proposed alternative high-speed rail passenger and freight service that is 405 

miles long. This proposal does not meet the project purpose and need and project 

objectives and is not technically feasible for reasons described in PH-F013-1. The 

proposal is infeasible for two reasons: because of length of tunnels and seismic 

issues and the incompatibility of standard U.S. freight service and high-speed rail 

passenger service (Standard Responses 2.7.1, 2.7.2, and 2.7.3). 

1

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

Mr. Cooper’s comments on the Final Program EIR/EIS are also addressed by the 

response to his earlier comments on the Draft Program EIR/EIS (see Final 

Program EIR/EIS comment number PH-F013-1). In addition, the Final Program 

EIR/EIS considered and rejected HST technology with maximum speeds of less 

than 200 mph (please see Final Program EIR/EIS, Standard Response 2.9.1). 

1.2.2 Joseph P. Thompson 

Joseph P. Thompson submitted an e-mail on September 12, 2005 and a letter and 

several attachments on September 13, 2005 in response to the publication of the 

notice of the Final Program EIR/EIS. The issues raised by Mr. Thompson have 

been previously addressed in response to Mr. Thompson’s comments on the Draft 

Program EIR/EIS (Comment Letter I015 dated March 10, 2004) and responses to 

other comments. 

Mr. Thompson restated his assertion that the proposed HST system should rely on 

private financing, rather than using public financing or receiving public subsidies. 

Mr. Thompson’s comments on the Final Program EIR/EIS regarding private sector 

financing of the HST system are fully addressed by the response to his earlier 

comments on the Draft Program EIR/EIS (see Final Program EIR/EIS Comment 

Letter I015). 

Mr. Thompson also submitted in support of his comments a number of publications 

by Wendell Cox, including a paper critical of the proposed Florida high speed train 

system, and wrote “Same for California” on this and other documents. 

Mr. Cox, asserting that the purpose of the Florida high-speed train system was to 

“reduce traffic congestion and provide transportation alternatives to the public” 

concluded that the Florida high speed rail proponents overestimated ridership, and 

underestimated costs, and that the proposed system would not drastically reduce 

traffic congestion. Mr. Cox also claimed that, in Florida, airport and freeway 

improvements would be more cost effective than high-speed rail. Mr. Thompson 

also submitted a January 1998 article titled “Infrastructure Project Forecasts: Major 

Inaccuracies,” in which Mr. Cox criticizes as inaccurate the cost projections for a 

number of major infrastructure projects. In his article titled “US Government Report 

Finds High Speed Rail to Require Heavy Subsidies: “Commercial Feasibility” 

Terminology Could be Misleading”, Mr. Cox quotes a 1996 FRA Report as finding 

that commercial revenues would fall far short of costs in all studies corridors 

(including Los Angeles – San Diego, and San Francisco – Los Angeles – San 

Diego). Mr. Cox notes that despite this finding the FRA concluded that high-speed 

rail would be commercially feasible in a number of the corridors (because they 

counted non-user and consumer surplus as commercial revenues). 

Reducing traffic congestion is not the purpose of the proposed HST system, and 

the Final Program EIR/EIS concludes that while the HST Alternative would have 

slightly less congestion than the No Project Alternative, “congestion would still 

increase on highways and the airports compared to existing conditions for both the 

2

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

Modal Alternative and the HST Alternative.” (page S-17) Standard Responses 

2.1.1 and 2.1.2 respond to comments concerning the Authority’s ridership and 

revenue forecasts. Standard Response 4.2.2 and Response to Comment O024-4 

respond to comments concerning the HST capital cost estimates. Maglev 

technology was eliminated from further investigation in the Final Program EIR/EIS. 

The Authority’s June 2000 Business Plan concluded that most of the HST system’s 

capital costs would need to be publicly financed. This conclusion is consistent with 

the FRA’s 1996 Commercial Feasibility Study referenced by Mr. Cox and 

consistent with Mr. Cox’s conclusion that high-speed train systems in North 

America would need to be largely publicly financed. However, both the Authority’s 

and the FRA’s cost/benefit analysis done for these respective studies found that 

the benefits (which included non-user benefits and consumer surplus) for HST 

would greatly outweigh the costs. A financing plan and an investigation relating to 

the subsidies (past and present) for air and automobile transportation are beyond 

the scope of this Final Program EIR/EIS. A comparison of the HST Alternative to 

potential highway and air transportation improvements (the Modal Alternative) is 

provided in the Summary of the Final Program EIR/EIS. 

1.2.3 John F. (Jack) Munro 

John F. (Jack) Munro submitted a letter dated October 15, 2005 in response to the 

publication of the notice of the Final Program EIR/EIS. The issues raised by Mr. 

Munro are in addition to Mr. Munro’s comments on the Draft Program EIR/EIS 

(Comment Letter I011 dated February 25, 2004). These new comments do not 

raise new issues concerning the Final Program EIR/EIS. Mr. Munro’s comments 

cover a variety of areas including shared use, freight service, double-deck 

passenger cars, electrification, the location of the San Francisco Terminus, and a 

potential station to serve Gilroy. 

• Mr. Munro states that sharing HST tracks with existing rail services “is not a 

good idea” and asks if the HST is being compromised to save money. The 

HST system described in the Final Program EIR/EIS (pages 2-30 & 2-31) 

“would operate in the majority of the statewide system in dedicated (exclusive 

track) configuration. However, where the construction of new separate HST 

infrastructure would be infeasible, shared track operations would use improved 

rail infrastructure and electrical propulsion. Potential shared-use corridors 

would be limited to sections of the statewide system with extensive urban 

constraints.” The two segments of the HST system identified for shared track 

operations with existing rail services are between San Francisco and San Jose 

and between Los Angeles and Orange County. The Authority has determined 

that sharing tracks in these corridors at reduced speeds is the most viable 

option for providing direct HST service to these markets (see Section 2.6.9 and 

Chapter 6A). 

• Mr. Munro states that “if you propose three different levels of service, a 

minimum of three tracks will be required, not two.” The Authority respectfully 

disagrees with this assertion. The Japanese have been operating several 

3

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

levels of service on their double track HST lines for decades (nearly 300 trains 

per day on the Tokaido Line). Intermediary HST stations would have off-line 

station stopping tracks (Table 2.6-2, page 2-27) to allow for express services 

and local stopping patterns. 

• Mr. Munro states that freight services on the HST tracks are only acceptable if 

the rolling stock is identical in performance to passenger equipment. This is 

consistent with the findings of the Final Program EIR/EIS (please see Standard 

Response 2.9.4). 

• Mr. Munro states that double-deck passenger cars are “unsuitable for highspeed service”. The Authority respectfully disagrees with this assertion. The 

Japanese (for over a decade) and the French both operate double-deck HST 

passenger cars. 

• Mr. Munro states that power demand will probably require dedicated generating 

stations. The Authority respectfully disagrees with this assertion. Energy 

requirements and impacts for the HST system are covered in Section 3.5 of the 

Final Program (please also see Standard Response 3.5.3). 

• Mr. Munro questions why HST tunnels were limited to 12 miles when the Swiss 

are building a 35-mile long tunnel. This issue is addressed on pages 2-9 & 2-

10 of the Final Program EIR/EIS (please also see Response to Comment PHF013-1). Although tunnels longer that 12 miles have been and are being 

constructed in other countries, the tunneling criteria for the HST system were 

developed for California’s unique geology and seismic conditions. 

• Mr. Munro states that the SF terminal should not be at 3rd and Townsend and 

that the best location would be at the Ferry Building. The Authority selected 

the Transbay Terminal as the preferred option for a SF terminal which is 

supported by the City of San Francisco and many other local agencies. There 

is no alignment identified or local plans to extend the Caltrain alignment to the 

Ferry Building. 

• Mr. Munro states that the HST alignment “must include Gilroy”. A broad 

corridor has been selected between the Bay Area and Central Valley, which 

could include a potential HST station at Gilroy. The selection of a preferred 

HST alignment between the Bay Area and Central Valley will be the focus of a 

subsequent “Bay Area to Central Valley HST Program EIR/EIS”. 

1.2.4 Dianne Domingo-Foraste M.D.; and Mayisha Akbar 

(founder of the Jr. Posse Youth Equestrian Culture 

Center 

Dianne Domingo-Foraste M.D. submitted an e-mail on October 29, 2005 and 

Mayisha Akbar submitted an e-mail on October 31, 2005 in response to the 

publication of the notice of the Final Program EIR/EIS. The issues raised by Ms. 

Domingo-Foraste, and Ms. Akbar have been previously addressed in the Final 

4

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

Program EIR/EIS and in response to others comments on the Draft Program 

EIR/EIS. 

Ms. Domingo-Foraste asserts that the impacts of the proposed HST system on the 

area known as “Taylor Yards” must be studied, Ms. Akbar states that it would take 

away open space promised to LA Residents, many who are minority and 

disadvantaged, both suggest that the Authority should re-route the HST system to 

another area such as LAX. Ms. Domingo-Foraste’s, and Ms. Akbar’s comments on 

the Final Program EIR/EIS regarding Talyor Yards are fully addressed by Standard 

Response 6.24.2. LAX was considered but rejected as a potential HST terminus 

station for Los Angeles as part of the Final Program EIR/EIS (see 2.6.8G, pages 2-

36 & 2-37). 

1.2.5 Joyce Dilliard 

Joyce Dilliard submitted an e-mail on October 31, 2005 in response to the 

publication of the notice of the Final Program EIR/EIS. The issues raised by Ms. 

Dilliard have been previously addressed in the Final Program EIR/EIS and in 

response to others regarding the level of detail of a program-level environmental 

process. 

Ms. Dilliard asserts that the Los Angeles connection needs to be addressed in the 

entirety of the region and lists a number of projects being discussed in the Los 

Angeles Metropolitan area, Ms. Dilliard suggests that the Authority should study 

LAX as an “alternative departure point”. The Final Program EIR/EIS addressed the 

Los Angeles connection in the entirety of the region as part of a study area that 

included most of the state from San Diego to Sacramento and the San Francisco 

Bay Area. This is a program-level EIR/EIS that would be followed by project-level 

environmental reviews that assess and address site-specific issues (see Standard 

Responses 3.15.2, 3.15.4, 3.15.6, & 3.15.13). LAX was considered but rejected as 

a potential HST terminus station for Los Angeles as part of the Final Program 

EIR/EIS (see 2.6.8G, pages 2-36 & 2-37), however a link to LAX from Los Angeles 

Union Station could be considered for a future expansion of the HST system 

should it be implemented (see 6A6.2, pages 6A-28 & 6A-29). 

1.2.6 Stuart Flashman on behalf of Train Riders 

Association of California, the Planning and 

Conservation League, and Defense of Place 

Stuart Flashman submitted a letter on October 28, 2005 commenting on the Final 

Program EIR/EIS. The issues raised by Mr. Flashman are in addition to comments 

submitted on the Draft Program EIR/EIS (Comment Letters PH-S011 and PH-S018 

on March 23, 2004, O029 on August 5, 2004, and O049 and O069 on August 31, 

2004). The October 28, 2005 letter raises new issues concerning the Final 

Program EIR/EIS, including- suggesting no action on the Final Program EIR/EIS in 

5

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

early November, requesting the removal of table 2-H-3 from the Appendices of the 

Final Program EIR/EIS, noting the Final Program EIR/EIS fails to account for the 

effects that different northern crossing alignments would have on alignment 

selection between Merced and Stockton/Tracy, and concern regarding the 

treatment of commuter ridership. Mr. Flashman also raised new issues on areas 

that were already addressed as part of previous comments on the Draft Program 

EIR/EIS in regards to the approach to analyzing impacts on parks, and reiterates 

previous comments on Draft Program EIR/EIS in regards to the adoption of 

feasible mitigation measures to mitigate the Project’s growth-inducing impacts. 

Request for Delay and No action on the Final EIR/EIS in early 

November 2005 

Noting the Final Program EIR/EIS “is a voluminous document,” Mr. Flashman 

requests the Authority not take action in early November and delay action for at 

least a month to allow further opportunity to meet with staff to address concerns 

regarding the adequacy of the document. The time provided between the 

announced availability of the Final Program EIR/EIS and the Authority’s meeting 

date is more than that necessary to meet CEQA and NEPA requirements, and 

Authority staff believe that the time provided has been sufficient. The Authority staff 

met with the Train Riders Association of California after the approval of staff 

recommendations to identify the Authority’s preferred alignment and station 

locations to discuss many of the concerns raised by Mr. Flashman. The Authority 

staff had several meetings and frequent communications with the Planning and 

Conservation League prior to the release of the Final Program EIR/EIS. The 

Authority staff will continue to meet with interested persons and groups as further 

studies proceed. Staff does not believe a delay in the Authority’s meeting or 

proposed action is needed. 

Requesting the removal of a table 2-H-3 from the Appendices of the 

Final Program EIR/EIS 

See “Erratum" at end of this attachment. 

Failure of the Final Program EIR/EIS to account for the effects that 

different northern crossing alignments would have on alignment 

selection between Merced and Stockton/Tracy 

Restudy of connections from the Central Valley to potential mountain passes 

(including the example stated above by Mr. Flashman) is included in the scope of 

the planned programmatic EIR/EIS for the Bay Area to Central Valley. In this way 

the Final Program EIR/EIS takes into account the potential for impact related 

connections in the Central Valley portion of the HST system. After describing the 

general northern mountain crossing study area, the Final Program EIR/EIS states 

in part on page 6A-10: 

6

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

The Authority in consultation with the FRA, has identified a broad preferred 

corridor between the Bay Area and the Central Valley containing a number of 

feasible route options which further study will permit the identification of a single 

preferred alignment option. This corridor is bounded generally by (and includes) 

the Pacheco Pass (SR-152) to the south, the Altamont Pass (I-580) to the north, 

the BNSF Corridor to the east, and the Caltrain Corridor to the west, but would not

include alignment options through Henry Coe State Park and station options at 

Los Banos.1 Future studies would focus on the identification of a preferred 

alignment between the Central Valley and the San Francisco Bay Area. 

Future studies would include consideration of: (1) how and where the HST 

alignment from the Bay Area would connect with the HST alignment in the Central 

Valley; (2) how and where the HST alignment would enter the Bay Area and 

would connect to Bay Area termini; (3) the location of stations within these 

segments. 

The preferences herein for portions of the Sacramento to Bakersfield alignment 

and stations, which are also in the broad corridor for further study between the 

Central Valley and the Bay Area (see above) are based on current information. 

These preferences are subject to change based upon the information provided in 

other future studies. 

Treatment of Commuter Ridership 

The HST system is proposed to primarily serve intercity trips (trips between 

regions) rather than local commuter trips. The Final Program EIR/EIS, however, 

acknowledges that among the 42-68 million annual riders forecast for 2020, an 

estimated 12 million passengers may be long distance commuters (please see 

Standard Response 1.1.33). The Final Program EIR/EIS did not address long 

distance commuter ridership between Tracy and San Francisco, as this alignment 

was not evaluated in the Final Program EIR/EIS and this would be appropriately 

addressed in future regionally focused studies. The Authority is working in 

partnership with the Metropolitan Transportation Commission (MTC) to complete 

new HST ridership and revenue forecasts which will take into account longdistance commuter trips. Study of the long-distance commuter potential between 

the Central Valley to the Bay Area via various potential mountain passes (including 

Tracy to San Francisco) will be included in the scope of the planned programmatic 

EIR/EIS for the Bay Area to Central Valley. 

The Approach to Analyzing Impacts on Parks 

Mr. Flashman raised new concerns about issues that were already addressed in 

response to the Planning and Conservation League’s (Comment Letter O049 on 

August 31, 2004) and California Department of Parks and Recreation’s (Comment 

Letter AS004 on August 19, 2004) comments on the Draft Program EIR/EIS. 

 

1 Highway route numbers are provided as a convenient reference for the reader, not as a limitation on the corridor to be 

considered. 

7

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

A key objective for the HST system is to avoid and/or minimize the potential 

impacts to cultural, park, and recreational resources and wildlife refuges. This 

objective, along with others, was used to eliminate several alignment options that 

would have potentially affected 4(f) and 6(f) resources, including parks. A table 

identifying each potentially affected resource and the nature of potential impact in 

terms of its relative proximity to the proposed facilities for both the Modal and HST 

Alternatives is provided in the Final Program EIR/EIS (Appendix 3.16-A). In 

addition, the “High-Speed Train Alignment Options Comparison” (pages 3.16-7 

through 3.16-10) highlights key differences between alignment options in regards 

to potential impacts to parklands. These differences included naming particularly 

sensitive/important 4(f) and 6(f) resources that may be impacted by the HST 

alignment options. For example, between the Bay Area and Merced, it was noted 

that the Hayward/Niles/Mulford option has a greater potential impact on the “highly 

sensitive Don Edwards San Francisco Bay National Wildlife Refuge” (page 3.16-7) 

than the Hayward/I-880 alignment option. As noted in Chapter 6A, this was one of 

the primary reasons that the Hayward/I-880 alignment was selected instead as the 

preferred alignment between Oakland and San Jose. The Final Program EIR/EIS 

states that the preferred HST alignment would not “run through” any State Parks 

(Page S-6), and of the State’s 278 State Parks, only five State Parks are within 900 

feet of the over 700-mile long preferred HST alignment – four of these are within 

existing, heavily used rail corridors adjacent to State Parks and the HST system 

would not be expected to greatly alter the existing environment, given these 

existing rail lines. 

The Adoption of Feasible Mitigation Measures to Mitigate the Project’s 

Growth-Inducing Impacts 

Feasible mitigation measures to mitigate potential growth inducing impacts were 

described in Chapter 6B of the Final Program EIR/EIS and are included in the 

MMRP. Please also see Standard Response 5.2.5 of the Final Program EIR/EIS. 

 

1.2.7 Sierra Club (signed by Patrick Moore, Chair, 

Transportation Committee, Loma Prieta Chapter) 

In addition to the letter dated October 31, 2005, submitted by the Sierra Club, 

Patrick Moore spoke on behalf of the Sierra Club on November 1. The issues 

raised by the Sierra Club are in addition to comments submitted on the Draft 

Program EIR/EIS (Comment Letter O003 on March 5, 2004, O067 on August 22, 

2004). The October 31, 2005, letter and the November 1 presentation from the 

Sierra Club raise new issues concerning the Final Program EIR/EIS, includingrequesting the removal of table 2-H-3 from the Appendices of the Final Program 

EIR/EIS, noting the Final Program EIR/EIS fails to account for the effects that 

different northern crossing alignments would have on alignment selection between 

Merced and Stockton/Tracy, concern regarding the treatment of commuter 

ridership such that the Sierra Club states mention of the Charles River Associates 

8

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

ridership study should be removed from the Final Program EIR/EIS. The Sierra 

Club also raised new issues on areas that were already addressed as part of 

previous comments on the Draft Program EIR/EIS in regards to the approach to 

analyzing impacts on parks. 

Requesting the removal of a table 2-H-3 from the Appendices of the 

Final Program EIR/EIS 

See “Erratum" at end of this attachment. 

Failure of the Final Program EIR/EIS to account for the effects that 

different northern crossing alignments would have on alignment 

selection between Merced and Stockton/Tracy 

Restudy of connections from the Central Valley to potential mountain passes is 

included in the scope of the planned programmatic EIR/EIS for the Bay Area to 

Central Valley. In this way the Final Program EIR/EIS takes into account the 

potential for impact related to connections in the Central Valley portion of the HST 

system. After describing the general northern mountain crossing study area, the 

Final Program EIR/EIS states in part on page 6A-10: 

The Authority in consultation with the FRA, has identified a broad preferred 

corridor between the Bay Area and the Central Valley containing a number of 

feasible route options which further study will permit the identification of a single 

preferred alignment option. This corridor is bounded generally by (and includes) 

the Pacheco Pass (SR-152) to the south, the Altamont Pass (I-580) to the north, 

the BNSF Corridor to the east, and the Caltrain Corridor to the west, but would not

include alignment options through Henry Coe State Park and station options at 

Los Banos.2 Future studies would focus on the identification of a preferred 

alignment between the Central Valley and the San Francisco Bay Area. 

Future studies would include consideration of: (1) how and where the HST 

alignment from the Bay Area would connect with the HST alignment in the Central 

Valley; (2) how and where the HST alignment would enter the Bay Area and 

would connect to Bay Area termini; (3) the location of stations within these 

segments. 

The preferences herein for portions of the Sacramento to Bakersfield alignment 

and stations, which are also in the broad corridor for further study between the 

Central Valley and the Bay Area (see above) are based on current information. 

These preferences are subject to change based upon the information provided in 

other future studies. 

 

2 Highway route numbers are provided as a convenient reference for the reader, not as a limitation on the corridor to be 

considered. 

9

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

Treatment of Commuter Ridership 

The HST system is proposed to primarily serve intercity trips (trips between 

regions) rather than local commuter trips. The Final Program EIR/EIS, however, 

acknowledges that among the 42-68 million annual riders forecast for 2020, an 

estimated 12 million passengers may be long distance commuters (please see 

Standard Response 1.1.33). The Final Program EIR/EIS did not address long 

distance commuter ridership between Tracy and San Francisco (Altamont Pass), 

as this alignment was not evaluated in the Final Program EIR/EIS and this would 

be appropriately addressed in future regionally focused studies. The Authority is 

working in partnership with the Metropolitan Transportation Commission (MTC) to 

complete new HST ridership and revenue forecasts which will take into account 

long-distance commuter trips. Study of the long-distance commuter potential 

between the Central Valley to the Bay Area via various potential mountain passes 

(including Tracy to San Francisco) will be included in the scope of the next-tier 

programmatic EIR/EIS for the Bay Area to Central Valley. 

In regards to the Charles River Associates ridership and revenue forecasts, please 

see Standard Response 2.1.1 and 2.1.2 as well as the detailed technical reports 

referenced in the Final Program EIR/EIS. The consideration for “any alternative 

operators, such as the San Joaquin Rail Authority, running their own commuter 

operations with a lower subsidized ticket price than what the Authority is prepared 

to charge” is beyond the scope of this program EIR/EIS process. Should the HST 

proposal move forward, more detailed studies of operations and potential operators 

will be completed. The Authority has determined that the Charles River Associates 

forecasts are appropriate for this Program EIR/EIS process. However, as noted 

above, the Authority is working in partnership with the Metropolitan Transportation 

Commission (MTC) to complete new HST ridership and revenue forecasts which 

will be available for future environmental studies. 

The Approach to Analyzing Impacts on Parks 

The Sierra Club raised new concerns about issues that were already addressed in 

response to the Planning and Conservation League’s (Comment Letter O049 on 

August 31, 2004) and California Department of Parks and Recreation’s (Comment 

Letter AS004 on August 19, 2004) comments on the Draft Program EIR/EIS. 

A key objective for the HST system is to avoid and/or minimize the potential 

impacts to cultural, park, and recreational resources and wildlife refuges. This 

objective, along with others, was used to eliminate several alignment options that 

would have potentially affected 4(f) and 6(f) resources, including parks. A table 

identifying each potentially affected resource and the nature of potential impact in 

terms of its relative proximity to the proposed facilities for both the Modal and HST 

Alternatives is provided in the Final Program EIR/EIS (Appendix 3.16-A). In 

addition, the “High-Speed Train Alignment Options Comparison” (pages 3.16-7 

through 3.16-10) highlights key differences between alignment options in regards 

to potential impacts to parklands. These differences included naming particularly 

sensitive/important 4(f) and 6(f) resources that may be impacted by the HST 

10

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

alignment options. For example, between the Bay Area and Merced, it was noted 

that the Hayward/Niles/Mulford option has a greater potential impact on the “highly 

sensitive Don Edwards San Francisco Bay National Wildlife Refuge” (page 3.16-7) 

than the Hayward/I-880 alignment option. As noted in Chapter 6A, this was one of 

the primary reasons that the Hayward/I-880 alignment was selected instead as the 

preferred alignment between Oakland and San Jose. The Final Program EIR/EIS 

states that the preferred HST alignment would not “run through” any State Parks 

(Page S-6), and of the State’s 278 State Parks, only five State Parks are within 900 

feet of the over 700-mile long preferred HST alignment – four of these are within 

existing, heavily used rail corridors adjacent to State Parks and the HST system 

would not be expected to greatly alter the existing environment, given these 

existing rail lines. 

1.2.8 U.S. Environmental Protection Agency 

The U.S. Environmental Protection Agency (EPA) submitted comments on the 

Final Program EIR/EIS for the proposed California High Speed Train (HST) 

System. 

EPA submitted comments on the cumulative impacts assessment in the Final 

Program EIR/EIS and made recommendations for the “Bay Area to Central Valley 

PEIS”, and for “Future Project-level Tier 2 NEPA Analyses”. 

Cumulative impacts assessment: EPA commented that the Final Program EIR/EIS 

did not contain a landscape–level cumulative impact assessment for all sensitive 

resources, and did not address a comprehensive set of reasonably foreseeable 

projects. EPA suggested that a different cumulative impacts analysis may have 

resulted in different conclusions or different mitigation options, and recommended 

that future environmental documents consider Caltrans guidance on cumulative 

impact assessments. Reasonably foreseeable future actions: EPA suggested that 

additional projects, such as large-scale developments and approved urban 

planning documents identified within and around the proposed high speed train 

system, should have been included in the cumulative impacts analysis as 

reasonably foreseeable future actions. 

Past and present actions: EPA disagreed with the Final PEIS’s characterization of 

past actions in the context of cumulative impacts analysis, and asserted that a 

landscape cumulative impacts analysis should include large scale mitigation, citing 

for example EPA’s assumption that a continuously-fenced high speed rail system 

would impede wildlife movement, and when considered with other past, present, 

and future project impacts to wildlife movement in California, would be potentially 

significant to a number of species. 

11

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

Response 

EPA’s recommendations for the Bay Area to Merced Program EIR/EIS and for 

future NEPA/CEQA review will be considered for these activities and efforts to 

coordinate with EPA will continue. Future cumulative impacts analysis and 

identification of mitigation will be based on appropriate study areas identified for 

individual resources. These study areas will be largely regional and local and they 

cannot be adequately identified until further information is known about alignment 

locations and the time period of implementation. Additional cumulative impacts 

analysis and identification of more refined mitigation will accompany project-level 

review. The Authority and the FRA find the Final Program EIR/EIS applied 

appropriate methodology to evaluate cumulative impacts from the proposed HST 

system at the program level and for decisions to be made on the Program EIR/EIS. 

Cumulative impacts assessment: The EPA letter does not raise new issues about 

cumulative assessment in the Final EIR/EIS that were not already addressed in 

response to EPA’s comments on the Draft EIR/EIS (Comment Letter AF008 in the 

Final EIR/EIS, dated August 31, 2004). 

The cumulative impact analysis in the Program EIR/EIS focused on the resources 

potentially affected by the proposed action and alternatives and identified where 

there may be added impacts to these resources, when considering past, present, 

and reasonably foreseeable future actions. The Program EIR/EIS described the 

current conditions that incorporate past and present effects of other recent projects 

in analyzing the potential for direct, indirect and cumulative impacts. The 

cumulative impact analysis considered reasonably foreseeable highway 

improvements and transit projects within the study area and extensively analyzed 

the potential for economic growth related cumulative and secondary effects for 

each of the three system alternatives. In addition, consideration of the indirect 

effects related to the reasonably foreseeable population and employment growth 

that could result from the proposed action and alternatives, as identified using local 

agency general plans and other planning documents, is addressed in the Final 

EIR/EIS (see Chapter 5, Economic Growth and Related Impacts), and is 

considered part of the cumulative impacts analysis. 

The methodology used is appropriate for this Program EIR/EIS due to the future 

time frame for the proposed HST system and the speculative nature of information 

about potential projects some 10 to 15 years in the future, and is consistent with 

CEQ Guidance. CEQ Guidance suggests that where evaluating reasonable 

foreseeable adverse effects and where there is incomplete information or 

unavailable information ...“that cannot be obtained because the overall costs of 

obtaining it are exorbitant or the means to obtain it are not known . . . the agency 

shall include ... the agency’s evaluation of such impacts based upon theoretical 

approaches or research methods generally accepted in the scientific community.” 

[CEQ Guidance “Considering Cumulative Effects,” p. 20; 40 CFR 1502.22] 

Past and reasonably foreseeable future actions: EPA’s suggested approach to 

future projects is not appropriate for this program analysis, and would be 

speculative for a proposed system that will not be implemented for at least 10 

12

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

years. Thorough analysis of site-specific, local area, and focused regional 

cumulative effects, including specific urban development projects, will be 

undertaken as part of future project-level environmental review, when this 

information will be available and more relevant to substantive impact analysis. 

For the Program EIR, the costs of attempting to collect detailed, timely, accurate 

data on projects which could be considered “reasonably foreseeable” some 10 to 

15 years in the future across all the jurisdictions represented by the HST 

Alternative conceptual corridors and the Modal Alternative components would be 

exorbitant and the means to obtain it are not assured. Given the limitations of 

available information, and the need to assess a future timeframe, the use of the 

growth analysis to address impacts from future development is an appropriate 

theoretical approach to cumulative impacts for this programmatic analysis. 

EPA’s suggestion that local general plans be used to identify reasonably 

foreseeable projects is not appropriate for this EIR/EIS. Every city and county is 

required by California law to adopt a general plan, but, except for housing 

elements, general plans are not comprehensively updated on a regular periodic 

basis pursuant to a statutory schedule. Each city and county determines when to 

update its general plan. Comprehensive updates are both unpredictable and 

irregular. Because at the beginning of the EIR/EIS process in 2001 the general 

plans for many of the jurisdictions with potential locations for HST facilities or 

components of the modal alternative were more than 10 years old, and some were 

more than fifteen or twenty years old, they were useful for identifying land use 

patterns and growth projections, but not individual projects. For preparing a 

cumulative impact analysis for thousands of miles of alternative transportation 

corridors, the general plans did not provide a reliable and consistent information 

base for identifying reasonably foreseeable future projects to use in analyzing 

cumulative impacts in a consistent manner for the system as a whole. The 

economic growth analysis in Chapter 5 addressed the relevant statewide and 

regional consequences of future actions that may be influenced by the choice of 

system alternative, and accounted for anticipated growth according to general 

plans without listing specific projects. The growth analysis properly considered 

available information, the timeframe for the implementation of the proposed HST 

system, the timelag in related projects potentially affecting resources, and the 

estimated secondary environmental impacts in jurisdictions in which HST facilities 

could potentially be located. In addition, appropriate mitigation was identified in 

Chapter 6B, Station Area Development, that could avoid, minimize, and mitigate 

potential cumulative and secondary effects. 

Cumulative Impact Analysis: EPA suggests using Caltrans guidance. This may be 

considered for future project-level documents. The Caltrans documents provide no 

guidance on cumulative impact analysis in programmatic EIS’s or EIRs, and no 

guidance on the temporal relationship of future projects to the proposed project, 

other than noting that reasonably foreseeable projects should be considered based 

on proximity in time and location 

Circumstances at locations across the proposed HST system vary widely; therefore 

identification of statewide or large-scale mitigation for cumulative effects is not 

13

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

appropriate. The Final Program EIR/EIS explains that the proposed HST system 

would traverse widely varied terrain with different soils, climate, topography, habitat 

conditions and species. It will be at grade, on aerial structures and in tunnels. It 

will include features to facilitate wildlife movement. However, because of the 

varied terrain it will cross, the impacts from the HST system will differ in different 

locations. Habitat for individual wildlife species is not continuous across the state 

but exists in distinct ecosystems. Movement requirements differ for individual 

species and in different locations. For example, there are great differences 

between the separate and distinct habitat types found in coastal Orange County, 

Soledad Canyon, Palmdale, and the Central Valley alignments. While coastal 

sage scrub habitat is a concern in Orange County, in the Central Valley there are 

different species and habitats of concern (e.g., San Joaquin Kit Fox). Each area 

has its own mix of habitat types, species, waters, climate and topography, as well 

as its own array of land uses and human population. The Program EIR/EIS 

included a broad analysis of the potential for cumulative impact by resource type. 

The Final Program EIR/EIS also identifies design practices and mitigation 

strategies for each resource/impact area, based on potential impacts identified in 

Chapter 3; Environmental Consequences. These mitigation strategies are also 

appropriate for the general types of impacts anticipated from cumulative effects. 

Additional analysis of cumulative impacts in local and regional contexts, and more 

refined mitigation measures, will be addressed during project-level reviews. 

1.2.9 Libby Lucas 

Libby Lucas submitted a letter on October 26, 2005 commenting on the Final 

Program EIR/EIS. This letter and the attached report do not raise new issues on 

the Final Program EIR/EIS that were not already addressed in response to Ms. 

Lucas’ comments on the Draft Program EIR/EIS (Comment Letter I139 on August 

30, 2004). 

Ms. Lucas’ letter of October 26 raised concern that additional regulatory agencies 

with jurisdiction in the vicinity of certain alignment options should have been 

consulted. 

Ms. Lucas’ comments on the Final Program EIR/EIS, are fully addressed by the 

response to her earlier comments on the Draft Program EIR/EIS (see Final 

Program EIR/EIS standard response number 6.3.1). The Authority and the FRA 

have determined that additional study will be needed in a separate program 

EIR/EIS in order to identify a preferred alignment alternative for the northern 

mountain crossing and that Altamont alignment options will be considered in that 

separate program EIR/EIS. A broad corridor containing a number of feasible route 

options has been identified for study. While the concerns raised in the comment 

letter regarding specific facilities and alignments may be identified in the separate 

program EIR/EIS, they will also be addressed in detail in subsequent project level 

environmental reviews. The San Francisco and Central Valley Regional Water 

Quality Control Boards and the Santa Clara Valley Water District were among the 

agencies that received notices and were coordinated with during the preparation of 

14

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

the Program EIR/EIS, as were the Water Quality Division of the State Water 

Resources Control Board and the California Department of Water Resources. In 

addition, the final EIR/EIS notice was published on September 16 in the Mercury 

News in San Jose and on September 18 in the San Francisco Chronicle. These 

agencies will also receive notices and be consulted in the preparation of future 

environmental documents which pertain to areas within their jurisdiction. 

1.2.10 State Parks 

The California Department of Parks and Recreation (State Parks) commented on 

the analysis of three issues in the Final Program EIR/EIS: (1) potential impacts to 

the five units of the State Park System that lie within 900 feet of the preferred HST 

north-south alignment, (2) impacts to wildlife corridors and connectivity between 

State Park System units and other open space or protected lands, and (3) potential 

impacts of the Bay Area to Central Valley (i.e., Merced) alignment that will be 

analyzed in a Second Tier Program EIR/EIS. Detailed comments were included on 

mitigation measures, alternatives, aesthetics, noise, environmental justice, 

recreation resources, cultural resources, geology and soils, biological resources, 

and cumulative impacts that substantially restate previously raised concerns, seek 

additional detailed studies and are critical of the responses provided to earlier 

State Parks comments on the Draft Program EIR/EIS. State Parks claims that the 

Final Program EIR/EIS does not provide adequate responses to its comments in 

order to comply with CEQA guidelines §15088, subd. (b). Finally, State Parks 

provided for use in future documents the new names given to the Taylor Yard and 

Cornfield park properties, and noted that Orestimba Wilderness had been 

misspelled in the Final Program EIR/EIS. 

At the November 1 Authority meeting, State Parks raised two additional concerns: 

a concern about consideration of compensation for loss of park use as mitigation 

and a concern that the Final Program EIR/EIS inadequately analyzed impacts to 

parks more than 900 feet from the HST system. 

Response 

The requested additional analysis of the state park system and particularly the five 

units that are identified as potentially affected by the selected HST corridor 

alignments, will appropriately be conducted during project-level environmental 

review. The Program EIR/EIS provides a consistent level of analysis for 

alternatives within the entire HST system, including thousands of corridor miles, 

includes design practices and mitigation strategies to avoid and minimize impacts 

to parks, and identifies steps for subsequent studies. The additional detailed 

analysis sought by State Parks would have been costly and speculative had it been 

performed at this time for the Program EIR/EIS. The potential for adverse impacts 

to parks that may not be fully avoided or reduced by mitigation was acknowledged 

in the Final Program EIR/EIS. 

15

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

In detailed comments State Parks fails to distinguish between the program level of 

analysis appropriate for the HST proposal due to its large scale and the more 

detailed, site specific studies that are appropriate for project level EIR/EIS’s or 

other more limited programmatic EIR/EIS’s, and fails to recognize that site-specific 

analysis are not necessary or required for the program decisions to be made based 

on the Final Program EIR/EIS. Future tiered environmental documents will be 

sufficiently comprehensive, and are the appropriate studies, to incorporate the 

additional information provided by State Parks (e.g., data from 2005 preliminary 

planning documents for the Rio de Los Angeles State Park (formerly known as 

Taylor Yard)) and to address the concerns raised by State Parks’ comments in 

greater detail. The Final Program EIR/EIS avoids impacts to many parks and, 

where potential impacts remain, the Final Program EIR/EIS incorporates mitigation 

strategies to avoid, reduce and minimize the potential impacts to parks. As State 

Parks’ comments recognize, potential impacts to park units may vary widely 

depending upon the rural or urban location, the resources at each park, the 

ambient noise environment, and other factors, all of which are appropriate for study 

in future environmental documents. Additionally, Section 4(f) and 6(f) findings will 

be made at the project level when alignments have been defined in more detail and 

after considering further variations to reduce and avoid impacts. Regarding wildlife 

movement, the Final Program EIR/EIS notes that up to 24% of the preferred HST 

system would be at-grade in new corridors and could present a barrier to wildlife 

movement, unless adequate features for wildlife crossings are included and 

incorporated in the system. The mitigation strategies in the Final Program EIR/EIS 

include underpasses or overpasses or other appropriate passageways at 

reasonable intervals to be designed during project level studies in order to avoid, 

minimize and mitigate potential impacts to wildlife movement. The design and 

placement details for features to facilitate wildlife movement are appropriately 

determined in the project level studies when more detailed information is available 

for alignments, HST facilities, and wildlife resources. 

Environmental justice, which was noted as a concern by State Parks, was 

addressed for the proposed HST system as a whole in the Program EIR/EIS, which 

satisfies all applicable requirements for program level review, and will receive 

additional study in future environmental documents for the HST system. 

Measurable low level EMF’s occur only in very close proximity to electric power 

facilities, and would generally be within the HST system right-of-way. Low level 

EMF’s occur with all electric power facilities and are not unique to the HST system. 

A variety of studies that have examined the effects of low-level EMF exposures on 

animals have found that general physiological status is relatively unaffected by lowlevel EMF exposures. Also, FRA data measuring EMF exposures after the 

Northeast Corridor Electrification Project found very low exposures levels in 

proximity to the train system. Further evaluation of potential EMF exposures will 

occur at the project level when specific species and locations can be examined 

along with more detailed project design information. 

After consultation with the President’s Council on Environmental Quality and the 

Resources Agency, the Authority and the FRA determined that additional study 

was needed of the proposed HST system connection between the Bay Area and 

16

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

the Central Valley before identifying a preferred alignment for this portion of the 

system. Rather than segmentation, this decision represents appropriate 

recognition of the limits of available data and need for further study, which will 

include review of connections in the Bay Area and the Central Valley, before 

additional decisions are made to select a preferred route in this area. 

The Final Program EIR/EIS provides adequate responses to comments in keeping 

with CEQA guidelines §15088, subd. (b), and incorporates as mitigation strategies 

many of State Parks’ mitigation suggestions, which will also be refined and applied 

in future environmental documents. At the November 1 Authority meeting, State 

Parks raised a concern about consideration of compensation for loss of park use 

as mitigation. That mitigation is included in the Final Program EIR/EIS for potential 

impacts to parks. In addition, State Parks expressed concern that the Final 

Program EIR/EIS inadequately analyzed impacts to parks more than 900 feet from 

the HST system. This issue was addressed in response to comment AS004-14. 

1.2.11 State Parks Foundation 

The California State Parks Foundation (in a letter signed by President Elizabeth 

Goldstein and presented in the November 1 Authority meeting ) commented on the 

analysis of these issues in the Final Program EIR/EIS: (1) the Final Program 

EIR/EIS “remains inadequate in its response to potentially significant park impacts 

and inappropriately defers critical analysis for land management, habitat 

preservation, cultural and biological resource management and noise and visual 

impacts to future project-level analysis”; (2) disagree that the use of existing rail 

corridors for HST operations is not expected to greatly alter the environmental 

effect of these existing rail lines; (3) disagrees that it is premature at this level of 

design to develop more specific mitigation measures for potential effects; (4) do not 

believe that sufficient information has been disclosed that would lead to a thorough 

assessment of the proposed project, particularly as it relates to potentially 

significant impacts on state parks; (5) encourage the Authority to establish an 

official Advisory Committee for Burbank to Los Angeles Union Station similar to 

that proposed for the Bay Area study. 

The Final Program EIR/EIS remains inadequate in its response to 

potentially significant Park Impacts 

Please see responses to letter from State Parks on the Final Program EIR/EIS. 

Disagree that the use of existing rail corridors for HST operations is 

not expected to greatly alter the environmental effect of these existing 

rail lines 

In alignments near parks where existing nearby passenger and freight trains are 

part of the ambient noise and visual environment, it is important to recognize that 

17

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

while the HST system is different than those services, the added impact may not 

be great, and the combined HST and conventional rail facility may improve existing 

local environments. In dense urban areas (such as at Taylor Yards and Old Town 

San Diego) the urban environment has elevated ambient noise levels, particularly 

where there are also freeways nearby and/or existing rail lines. When traveling at 

reduced speeds the HST is quieter than existing freight and conventional 

passenger trains. Moreover, when the HST shares rights-of-way with conventional 

rail, grade separation improvements and/or sound walls or other mitigation 

measures will reduce existing noise levels and other existing environmental 

impacts in these corridors. 

Disagree that it is Premature at this Level of Design to develop more 

specific mitigation measures for potential effects 

The need for further study is inherent to the first phase of a tiered environmental 

process that is followed by further studies and it is entirely proper for further study 

of discrete issues to be included in future project-level environmental documents, 

which will be more detailed. The Final Program EIR/EIS contains mitigation 

strategies appropriately identified at the program level and notes that such 

strategies will be refined and applied at the project level. Additional steps will be 

taken at the project-level to avoid impacts to parks by considering alignment 

variations. The Authority is committed to avoiding Henry Coe State Park, and will 

continue to apply avoidance and mitigation strategies in future studies regarding 

other State Parks. 

Do not believe that sufficient information has been disclosed that 

would lead to a thorough assessment of the proposed project, 

particularly as it relates to potentially significant impacts on state 

parks 

This comment has been addressed as part of the Final Program EIR/EIS. Please 

refer to Standard Responses 3.15.2, 3.15.4, 3.14.6, 3.15.13 and the Summary of 

the Final Program EIR/EIS. 

Encourage the Authority to establish an official Advisory Committee 

for Burbank to Los Angeles Union Station similar to that proposed for 

the Bay Area study 

The Authority has not formed any official advisory committees for its upcoming Bay 

Area to Central Valley HST Program EIR/EIS process. It is premature to make any 

commitment at this time on official advisory committees for future study of parts of 

the system; however, such committees will be considered in the future. 

18

CALIFORNIA HIGH SPEED RAIL AUTHORITY
Staff Summary of and Brief Response to 

Comments on the Final Program EIR/EIS 

1.2.12 City of Visalia 

Mayor Bob Link of the City of Visalia spoke in support of the Final Program 

EIR/EIS at the November 1 Authority meeting. 

1.2.13 City of Palmdale 

Laura Biery of the City of Palmdale, speaking at the November 1 Authority 

meeting, supports the proposed HST system with the selection of the Antelope 

Valley/Palmdale route as part of the preferred system. 

1.2.14 Natural Resources Defense Council 

James Birkelund of the Natural Resources Defense Council (NRDC) spoke at the 

November 1 Authority meeting. He expressed support for the project in concept, 

and reiterated NRDC’s comments made on the Draft Program EIR/EIS. These 

issues were responded to in the Final Program EIR/EIS O015-1 through 14. 

1.3 Erratum 

The following erratum is in addition to and supplements the Errata contained in the 

Staff Report of October 2005. 

The inclusion of Table 2-H-3 in the appendices of the Final Program EIR/EIS was 

an error. The inclusion of Table 2-H-3 in the Appendices and its reference in 

Chapter 2 of the Final Program EIR/EIS is hereby removed from the Final Program 

EIR/EIS. 

19

CALIFORNIA HIGH SPEED RAIL AUTHORITY